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of <h1>Taxation statutes require strict construction with ambiguous provisions favoring taxpayers over implied unstated provisions</h1> Strict construction principles require taxation statutes to be interpreted narrowly according to their literal meaning without equitable considerations. The subject cannot be taxed without clear statutory words, and ambiguous provisions favor the taxpayer. Courts must adhere strictly to statutory language without implying unstated provisions or filling deficiencies. However, strict interpretation differs from pure literalism as it considers apparent legislative intent to avoid absurdity. While penal statutes also follow strict construction, modern interpretation has evolved to consider purpose, object, text, and context alongside literal meaning, moving away from purely mechanical application toward purposive interpretation that advances legislative objectives.
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